ISM Code Element 7 · COSWP, ISGOTT Ch. 9 & LOTO
Permit to Work, Hot Work & Working Aloft Checklist: LOTO, Gas Testing & Close-Out
Under ISM Code Element 7 (Shipboard Operations), the Code of Safe Working Practices for Merchant Seafarers (COSWP), and ISGOTT 6th Edition Chapter 9, high-risk maintenance tasks on board may only proceed under a formal, time-limited Permit to Work (PTW) supported by a task-specific Risk Assessment, Lock-Out / Tag-Out (LOTO) isolation, and a pre-job Toolbox Talk.
During SIRE 2.0 (Chapter 2 & Chapter 5), RightShip RISQ 3.2 (Section 4), CDI and Port State Control inspections, vetting inspectors routinely audit the ship’s file of completed permits against deck/engine logbooks and gas-detector records. This guide sets out the mandatory checks for Hot Work, Working Aloft / Overside, Electrical LOTO and Enclosed Space Entry.
Updated · Written by SeaReady in our own words. Not affiliated with OCIMF, RightShip, CDI, any MoU or any administration — always check the current official documents.
1. Core Shipboard Permit to Work Categories & Authorization Rules
A Permit to Work is never a mere piece of paper; it is a physical verification loop covering Preparation & Isolation, Gas/Safety Verification, Active Supervision, and Formal Hand-Back & Close-Out:
| Permit Type | Approving Authority & Validity | Mandatory Controls & Isolation Checks |
|---|---|---|
| Hot Work Permit (Outside Designated Engine Room Workshop) | Master’s signature + Company/DPA office concurrence (where required by SMS / ISGOTT Ch. 9) | Required for any welding, flame cutting, grinding or open-flame work outside the designated engine-room workshop. Requires a formal risk assessment, gas-free check (< 1% LEL and 20.9% O2, including adjacent and below spaces), removal of combustibles within 10 m, dedicated fire watch with charged fire hose/extinguishers during work and for at least 30–60 minutes after completion, and isolation of local fire-detection zone only during active work. |
| Enclosed Space Entry Permit (SOLAS III/19 & IMO Res. A.1050(27)) | Master or responsible officer authorization (valid for 1 shift / ≤ 8–12 hours, never overnight) | Mandatory before entering any cargo hold, ballast tank, double bottom, cofferdam, chain locker, fuel/lube oil tank, void space or crankcase. Requires continuous mechanical ventilation, calibrated multi-gas pre-entry test (20.9% O2, < 1% LEL, < 5 ppm H2S, < 25 ppm CO), dedicated attendant at the entrance with UHF radio, personal multi-gas monitor on every entrant, and rescue tripod/EEBD/SCBA staged at the hatch. |
| Working Aloft & Overside Permit (COSWP Ch. 17) | Chief Officer / Chief Engineer authorization | Required whenever work is carried out ≥ 2 metres above deck/stage or over the ship’s side. Requires a full-body safety harness with double lanyard and shock absorber attached to an independent strongpoint (never the stage itself), tool lanyards, isolation of radar scanners, ship’s whistles and radio transmitter aerials (GMDSS MF/HF), and a standby person on deck with lifebuoy and line. |
| Electrical Isolation & Lock-Out / Tag-Out (LOTO — COSWP Ch. 20) | Chief Engineer / ETO & Responsible Officer | Required before working on switchboards, motors, cargo pumps, bow thrusters, radar masts or high-voltage (> 1,000 V AC) equipment. The circuit breaker must be racked out or locked open with a physical padlock and personal danger tag, proved dead with a calibrated voltage tester tested before and after use, and earthing applied for high-voltage circuits. |
| Cold Work, Pressure Pipeline & Underwater Diving Permits | Responsible Officer / Master | Covers opening pressurized fuel, steam, hydraulic or cargo lines (requiring double isolation, depressurization and flange spading/blinding), crane/heavy-lift operations, and commercial hull diving / ROV cleaning (requiring main engine turning gear engagement, sea-chest valve lock-out, ICCP impressed current cathodic protection switch-off, and Code Flag Alpha display). |
2. Hot Work Outside the Engine Room Workshop: Gas Testing & Fire Watch
Hot work on deck, in cargo holds, in pump rooms or near fuel tanks is one of the leading causes of catastrophic shipboard fires and explosions. Under ISGOTT 6th Edition Chapter 9 and COSWP Chapter 24, hot work outside the designated workshop is prohibited unless no practicable cold-work or shore-repair alternative exists and the following conditions are verified:
| Hot Work Parameter | Mandatory Threshold | Verification & Supervision Rule |
|---|---|---|
| Oxygen (O2) | 20.9% by volume | Tested immediately before starting hot work and continuously monitored in the work space and any adjacent enclosed space. |
| Flammable Vapours (LEL) | < 1% LEL (0% LEL required by many tanker SMS / ISGOTT 6th Ed. Ch. 9) | Any surface scale, sludge or paint coating within the heat-affected zone (including the reverse side of bulkheads/decks) must be cleaned bare so heating does not evolve hydrocarbon vapour. |
| Adjacent & Below Spaces | Inspected, gas-tested & cleared of combustibles | Heat conducts rapidly through steel decks and bulkheads; a fire watch must check the opposite side of any bulkhead or deck head being welded or ground. |
| Post-Work Fire Watch | Continuous watch during work + ≥ 30–60 minutes after completion | After hot work ends, the area must be inspected repeatedly for smouldering sparks before the fire-detection zone is re-enabled and the permit is signed closed. |
- Electric arc & oxy-acetylene equipment checks: Verify that electric welding return leads (earth clamps) are connected directly to the workpiece as close to the weld as possible (never using the ship’s hull structure as the return path), welding cables are fully insulated with no taped joints, and oxy-acetylene hoses are fitted with flashback arrestors at both the regulator and torch ends.
- Prohibition during cargo, bunkering or ballasting: Never carry out hot work on deck or in the machinery space while cargo operations, tank cleaning, gas freeing, purging or bunkering operations are in progress.
3. Lock-Out / Tag-Out (LOTO), Working Aloft & Permit Close-Out Audit
Before an inspector arrives, the Chief Officer and Second Engineer should audit the last 90 days of permits and the ship’s physical LOTO station:
- Physical LOTO padlocks, hasps & register: Check that the Engine Control Room (ECR) and Cargo Control Room (CCR) LOTO boards have numbered padlocks, multi-lock hasps, circuit-breaker lockouts, valve wheel lockouts and durable danger tags, and that every active isolation is recorded in the LOTO Isolation Register with the key held by the person performing the work.
- Safety harnesses & fall-arrest inspection log: Verify that every full-body harness, shock-absorbing double lanyard, inertia reel and bosun’s chair / stage has a unique serial number, is inspected before each use and quarterly in the lifting/PPE register, and is stored away from chemicals, sunlight and grease.
- Every completed permit must be signed closed: Confirm that every expired or completed permit has its final Work Completed / Equipment Restored / Fire Zone Re-enabled section signed and timed by both the person in charge of the work and the authorizing officer.
Questions seafarers ask
Why do SIRE 2.0, RightShip RISQ and PSC inspectors audit closed Permits to Work from the last 3 months?
Inspectors do not just check whether blank permit forms exist in the SMS manual; they pull 5 to 10 completed Permits to Work (Hot Work, Enclosed Space Entry, Working Aloft, Electrical LOTO) from the previous 90 days and cross-check them against the Deck and Engine Logbooks, the fire-alarm zone isolation log, the gas-detector calibration/bump-test log, and crew rest-hour records. Common deficiencies include permits that were never signed closed in Section 4/5 after completion, validity periods exceeding 12 hours, or identical photocopied risk assessments used for different jobs.
What makes an engine-room workshop a "Designated Hot Work Area" under ISGOTT and COSWP?
The engine-room workshop is only treated as a designated safe hot-work space if it meets strict construction and operational criteria: solid steel bulkhead separation from machinery bilges and fuel tanks, positive mechanical ventilation, welding curtains/screens, dedicated local fire extinguishers and sand/blanket, gas-free atmosphere, and clean workbenches free of oily rags or open solvent cans. Even for workshop welding, many tanker and bulk carrier Safety Management Systems require a simplified workshop hot-work checklist or Chief Engineer sign-off during cargo or bunkering operations.
What is the difference between a Permit to Work and a Toolbox Talk (Pre-Job Safety Meeting)?
A Risk Assessment and Permit to Work establish the formal engineering controls, isolations (LOTO), atmosphere tests and rescue equipment required before a hazardous job is authorized. The Toolbox Talk (Pre-Job Safety Meeting) happens at the actual work site immediately before the job starts: every rating, cadet, officer and fitter involved walks through the specific steps, stop-work authority, communication signals, personal protective equipment (PPE) and emergency escape route.
What precautions must be taken on the bridge before issuing a Working Aloft permit near the mast?
Before anyone climbs the radar mast, monkey island or funnel casing, the Officer of the Watch (OOW) must isolate and padlock the X-band and S-band radar scanners, isolate the ship’s forward and aft air/electric whistles (tyfon), isolate MF/HF and Inmarsat/VSAT high-power transmitters to prevent RF radiation burns, and place prominent "MEN WORKING ALOFT — DO NOT OPERATE" warning tags on every bridge console switch.
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Related guides
- Enclosed space entry checklistIMO MSC.581(110) atmosphere limits, SOLAS XI-1/7 gas meters, the permit and 2-monthly drills.
- ISM internal audit & DPA checklistSOLAS Ch. IX & ISM Code Elements 1–16, DPA, Master’s annual review, 12-month audit window and avoiding PSC Code 30.
- ISGOTT 6 & BLU ship/shore safety checklistISGOTT 6th Edition Parts 1A–9 (tanker/LPG/LNG) and IMO BLU Code Appendix 3 (dry bulk) ship/shore safety checks.
- SIRE 2.0 inspection checklistChapter by chapter: what the inspector looks at and the evidence to have ready.